Supreme Court Restores Promotion of Tamil Nadu Teacher in Eligibility Dispute image for SC Judgment dated 18-02-2022 in the case of A. Dharmaraj vs The Chief Educational Officer,
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Supreme Court Restores Promotion of Tamil Nadu Teacher in Eligibility Dispute

The Supreme Court has ruled in favor of A. Dharmaraj, restoring his promotion to the position of B.T. Assistant (English), which was previously set aside by the Madras High Court. The decision, delivered on February 18, 2022, overturned the High Court’s ruling that disqualified the appellant due to obtaining two degrees simultaneously.

The case revolved around an interpretation of Rule 14, which bars candidates from obtaining B.A./B.Sc./B.Ed. degrees in the same academic year. The Supreme Court found that the appellant had pursued his degrees in different academic years and was thus wrongly disqualified.

Background of the Case

The appellant, A. Dharmaraj, was promoted to the post of B.T. Assistant (English) by an order dated August 6, 2016. However, this promotion was challenged by another candidate, leading to legal proceedings:

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  • A writ petition (No. 15019 of 2016) was filed before the Madras High Court, challenging the appellant’s promotion.
  • The Single Judge of the High Court ruled against Dharmaraj, stating that he had violated Rule 14 by obtaining two degrees—B.A. (English) and M.A. (Tamil)—at the same time.
  • The Division Bench of the High Court upheld the Single Judge’s order, prompting the appellant to approach the Supreme Court.

Petitioner’s Arguments

The petitioner, A. Dharmaraj, argued:

  • He had pursued his B.A. (English) from January 2012 to December 2014 and his M.A. (Tamil) from 2013 to 2015. Since they were completed in different academic years, he did not violate Rule 14.
  • Rule 14 applies only to cases where a candidate obtains B.A./B.Sc./B.Ed. degrees in the same academic year. Since his degrees were in different subjects and academic years, the rule should not apply to him.
  • Even if his M.A. (Tamil) degree was ignored, his B.A. (English) degree was sufficient for eligibility.

Respondents’ Arguments

The respondents, including the Chief Educational Officer, Pudukkottai, contended:

  • The appellant had simultaneously pursued two degrees, which was a violation of Rule 14.
  • The High Court had correctly interpreted the rule and set aside his promotion.
  • The appellant should not have been allowed to hold a teaching post under such circumstances.

Supreme Court’s Observations

The Supreme Court ruled in favor of the appellant, holding that:

“The promotion of the appellant to the post of B.T. Assistant (English) has been set aside by the High Court on the ground that the appellant obtained two degrees simultaneously and therefore as per Rule 14 he was ineligible for promotion. However, considering Rule 14, it can be seen that the bar was against teachers who have obtained B.A./B.Sc./B.Ed. degree simultaneously during the same academic year.”

On Interpretation of Rule 14

The Court clarified that Rule 14 does not prohibit candidates from obtaining different degrees in separate academic years:

“In the present case, it cannot be said that the appellant obtained the degree of B.A. (English) and M.A. (Tamil) during the same academic year. The appellant pursued his B.A. (English) during January 2012 to December 2014. He pursued his M.A. (Tamil) which was a two-year distance education course between the academic years 2013-2014 to 2014-2015.”

On the Eligibility of the Appellant

The Court further held that even if his M.A. (Tamil) degree was ignored, the appellant still qualified for the promotion:

“Assuming that the subsequent degree obtained by the appellant namely M.A. (Tamil) is ignored, in that case also, considering his degree in B.A. (English) he could have been promoted to the post of B.T. Assistant (English). Both the degrees secured by the appellant cannot be ignored. It is not in dispute that the degree of B.A. (English) was sufficient as per the eligibility criteria for promotion to the post of B.T. Assistant (English).”

Final Judgment

The Supreme Court delivered the following rulings:

  • The promotion of the appellant is restored.
  • The judgment of the Madras High Court, both at the Single Judge and Division Bench level, is quashed.
  • The writ petition filed by the contesting respondents is dismissed.

The Court concluded:

“The present appeal succeeds. The impugned judgment and order passed by the Division Bench of the High Court in Writ Appeal (MD) No. 834 of 2018 and also the judgment and order passed by the learned Single Judge in Writ Petition No. 15019 of 2016 are hereby quashed and set aside. The order of promotion promoting the appellant to the post of B.T. Assistant (English) dated 06.08.2016 stands restored.”

Implications of the Judgment

This ruling has significant implications:

  • Clarification on Rule 14: The decision clarifies that Rule 14 does not apply to cases where degrees are obtained in different academic years.
  • Recognition of Distance Learning Degrees: The ruling upholds the validity of degrees obtained through distance education, provided they comply with existing eligibility norms.
  • Fair Promotion Practices: The judgment reinforces that promotions should not be arbitrarily set aside based on misinterpretations of rules.

The Supreme Court’s verdict ensures that the appellant retains his rightful position, setting a precedent for similar cases in the future.


Petitioner Name: A. Dharmaraj.
Respondent Name: The Chief Educational Officer, Pudukkottai & Ors..
Judgment By: Justice M.R. Shah, Justice B.V. Nagarathna.
Place Of Incident: Tamil Nadu.
Judgment Date: 18-02-2022.

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